HEALTH OFFICIAL RAISES CONCERNS OVER PROPOSED METHADONE CLINIC

WISE - Planning District 1-Behavioral Health Services Executive Director Sam
Dillon has forwarded a number of health care-based concerns over a proposed
methadone clinic in the town of Pound to Virginia's health provider
licensing agency.

Last month, Bristol-based Appalachian Treatment Services (ATS) applied to
operate a methadone clinic on Indian Creek Road in Pound. The Planning
District 1 board had until the middle of this month to send a response to
the Virginia Department of Mental Health, Mental Retardation and Substance
Abuse Services (MHMRSAS).

In a two-page letter dated Sept. 3 and sent to Ralph E. Strouge, a regional
manager of the MHMRSAS office of licensing, Dillon raised clinical concerns
"as well as issues about proposed staffing, linkages to our services and
other agencies and existing services, and the need for this clinic in this
locality."

Dillon did not bring up the matter of Pound's zoning ordinances. Wise County
Building Inspector Robert Mullins, who also serves as Pound's zoning
administrator, said two weeks ago the site identified in the ATS proposal is
within an R-2 zone, or strictly residential area.

The building eyed by ATS for its clinic was grandfathered into the R-2 zone
because it was an existing business when the zoning boundaries were drawn
up. However, the zoning ordinance strips the grandfathered status if the
business is empty for more than 24 months. Mullins said the building in
question no longer qualifies for a grandfather exemption because it has been
empty more than two years.

Dillon's concerns to state licensing officials cover a range of health care
issues, including:

- - Needs assessment - PD-1 asserts that ATS has not completed or referenced a
needs assessment, although it projects the number of persons to be served at
a Pound facility during its first year would be 150.

Dillon said that is more than double the number of opiate-dependent persons
in Wise County "and these persons are currently receiving services via
alternate treatment modalities" such as abstinence, counseling, case
management and detox. He notes that ATS doesn't include residents of Pound
or the county in its populations-to-be-served analysis, but identifies
Washington County, Va., and Upper East Tennessee "as its catchment area."

Dillon said there is an existing methadone clinic in Hazard, Ky., about 50
miles from Pound.

- - Coordination of care - Dillon said as of the date of the letter, ATS has
made no contact with the local Community Services Board, health department
or any other local agencies or providers.

- - Medical emergencies - Dillon states there is no provision in the proposal
for readily available emergency medical services "and therefore, no plan."

- - Medical oversight/qualifications - Dillon said the PD-1 staff is concerned
about a lack of a specific plan to provide adequate screening and treatment
"for the very vulnerable population" of pregnant women, and no stated plans
to develop resources to serve them.

- - Aftercare/discharge planning - The "sole effort" of ATS to address
adequate discharge planning is the company's references to the Directory of
Treatment Services in Virginia, which Dillon asserts "does not constitute
adequate discharge planning."

- - Staffing - Dillon says the staff-to-consumer ratio of one staffer to every
60 clients "seems at least inadequate, given the numbers of persons to be
served and the severity of their biopsychological needs."

- - Alternate treatment/treatment philosophy - ATS does not offer other plans
or procedures to verify that treatments other than providing clients with
doses of methadone "have been proposed, or even discussed," Dillon wrote.

- - Accreditation - ATS is "vague about actual timetables, processes, and type
of accreditation pursued," Dillon wrote.

He also raised concerns about indigent consumers and said ATS stated no
provisions in its application for consumers "with a diminished ability to
pay."

"In summary," he wrote, "we have real concerns about the efficacy of this
stand-alone approach to treatment, and what it will bring to our community."

Methadone is a synthetic opiate once touted as a means to wean people from
their addiction to heroin. Critics claim methadone is not a treatment but
simply trades an illegal drug dependency for a legal addiction and is not
effective without providing other treatments like detox, abstinence,
counseling and case management.